Estate of Gertrude Saunders v. Cir

OPINION

M. SMITH, Circuit Judge:

In this appeal from the tax court, we consider whether the Estate of Gertrude Saunders (the Estate) properly claimed a $30 million deduction on its estate tax return for a lawsuit pending at the time of Gertrude Saunders’ death (the Stonehill Claim, or the Claim), even though the suit ultimately settled for a smaller sum. The Commissioner of Internal Revenue (the Commissioner) disallowed the $30 million deduction. Because the estimated value of the Stonehill Claim at the time of Gertrude Saunders’ death was not ascertainable with reasonable certainty, the tax…